The FTC’s 20-Year-Consent-Order Policy Is Burdensome and Unfair

Partner John Villafranco authored ​“The FTC’s 20-Year-Consent-Order Policy Is Burdensome and Unfair” published by Bloomberg Law. The article discusses the Federal Trade Commission’s 20-year consent order duration, which the agency has not revisited since 1995. Other federal agencies’ consent order duration is much shorter. John argues that the FTC should adopt a new position on consent orders lasting five to 10 years.

“Compliance requires a substantial operational and financial investment over 20 years or more. In our experience, this often costs businesses tens of millions of dollars and hundreds of labor hours over the course of the order. These compliance costs burden businesses for far longer than is necessary to achieve an order’s purpose.”

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